Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
The article determines that technical-grade Cyantraniliprole and Clothianidin are insecticidal preparations and thus classifiable under Heading 3808. Applying Chapter and HSN explanatory notes and GRI 3(a), the specific description for insecticidal preparations prevails over more general chemical headings; alternatively, GRI 3(b) supports classification by essential character derived from insecticidal function. Supplementary Note 2's mass-content threshold (>90%) is satisfied, bringing the goods within the specified tariff entry for technical-grade pesticides. Legislative amendments in the Finance Act, 2025 and product registration requirements under the Insecticides regime reinforce their regulatory identity as insecticides.
The article determines that technical-grade Cyantraniliprole and Clothianidin are insecticidal preparations and thus classifiable under Heading 3808. Applying Chapter and HSN explanatory notes and GRI 3(a), the specific description for insecticidal preparations prevails over more general chemical headings; alternatively, GRI 3(b) supports classification by essential character derived from insecticidal function. Supplementary Note 2's mass-content threshold (>90%) is satisfied, bringing the goods within the specified tariff entry for technical-grade pesticides. Legislative amendments in the Finance Act, 2025 and product registration requirements under the Insecticides regime reinforce their regulatory identity as insecticides.
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